BHOJRAJ WASUDEORAO KORAMKAR,NAGPUR vs. DEPUTY COMMISSIONER OF INCOME TAX CENTRAL CIRCLE 1(1), NAGPUR, NAGPUR

ITA 680/NAG/2025Status: DisposedITAT Nagpur18 June 2026AY 2018-1914 pages
AI SummaryAllowed

What did the Tribunal hold?

The Tribunal held that the exemption under Section 54F cannot be denied solely on the technical ground that it was not claimed in the return of income, especially when the eligibility and all relevant facts are on record. The lower authorities' denial of the deduction was deemed unjustified.

What were the facts?

The assessee sold agricultural land and claimed exemption under Section 54F for purchasing a residential flat. The Assessing Officer (AO) denied the exemption because it was not claimed in the original or revised return, though the eligibility was not disputed. The CIT(A) upheld the AO's decision.

What were the issues?

Whether exemption under Section 54F can be denied if not claimed in the return of income, despite all facts being on record. Whether appellate authorities can entertain such claims not made before the AO.

Which sections of the Income-tax Act were involved?

Section 54F,Section 147,Section 148,Section 139,Section 250,Section 254

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, NAGPUR BENCH :: NAGPUR

For Appellant: Shri K.P. Dewani, Advocate
For Respondent: Shri Pankaj Kumar, CIT-DR
Hearing: 16.06.2026Pronounced: 18.06.2026

PER KHETTRA MOHAN ROY, AM:

This appeal filed by the assessee is directed against the order of Commissioner of Income Tax (Appeals)-3, Nagpur, (for short, “CIT(A)”), dated 19/09/2025 passed under section 250 of the Income Tax Act, 1961 (for short, “Act”) which is emanating from the assessment order dated 25.03.2025 passed u/s. 147 of the Act by the DCIT, Central Circle-1(1), Nagpur, for the Assessment Year (AY) 2018-19. 2. The assessee has raised the following grounds of appeal: 1) The order passed by Commissioner of Income Tax (Appeals)-3, Nagpur is without providing reasonable opportunity of being heard and is in violation of principles of natural justice. Dismissal of grounds is unjustified and unwarranted.

The order continues below.

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